Bernabe Foster-Gallego v. Spouses Romeo and Vivien Galang
REITERATIONFacts
The Antecedents: Vive Realty Corporation (VRC) acquired a parcel of land at a public auction. VRC sold the property to Spouses Galang, who obtained a new title and paid real property taxes. Lito Gallego, claiming his brother Bernabe Foster-Gallego (petitioner) owned the property, built a fence on it. Spouses Galang filed a complaint for Quieting of Title with Damages against Lito Gallego. Procedural History: Lito Gallego was declared in default. Petitioner filed a motion for intervention, which was initially granted, and later a third-party complaint. The case was raffled to several RTC branches. Petitioner's motion to strike proceedings and hold hearings in abeyance was denied, and this denial was affirmed by the Court of Appeals and the Supreme Court. The trial court eventually ruled in favor of Spouses Galang, declaring them owners and ordering Lito Gallego to pay damages. The trial court later reconsidered and denied petitioner's intervention and third-party complaint. Petitioner appealed this denial, but the Court of Appeals dismissed his appeal for being filed out of time and for lack of legal personality to join Gallego's appeal. The Court of Appeals affirmed the trial court's decision but deleted the award of damages. The Petition: Petitioner filed a petition for review on certiorari assailing the Court of Appeals' decision, arguing that the trial court erred in denying his intervention and third-party complaint, that the auction proceedings and subsequent titles were void, and that he was an indispensable party.
Issue(s)
Whether the Court of Appeals erred in dismissing petitioner's appeal from the trial court's orders disallowing petitioner's intervention. Whether RTC-Branch 138's Decision of December 19, 1983, can be declared void in an action for quieting of title. Whether petitioner is an indispensable party to the action for quieting of title.
Ruling
The Supreme Court denied the petition and affirmed the decision of the Court of Appeals. The Court held that the petitioner's appeal was correctly dismissed for being filed out of time and for lack of legal personality to join the appeal of another party. The Court further ruled that an action to quiet title cannot be used to annul or modify the judgment of a co-equal court, and that a cancelled title cannot cast a cloud on a current title. Petitioner was also found not to be an indispensable party.
Ratio Decidendi
On the issue of the Court of Appeals dismissing petitioner's appeal: The Court affirmed the Court of Appeals' finding that petitioner's appeal was filed out of time. The records showed that petitioner filed his notice of appeal two days after the deadline, even after filing a motion for reconsideration. The perfection of an appeal within the reglementary period is jurisdictional, and failure to do so renders the judgment final and executory. Petitioner's argument that the one-day tardiness was excusable due to a clerical error was not considered a valid justification for a late appeal, as exceptional circumstances are required to allow late appeals, which were not present here. Furthermore, the Court reiterated that a prospective intervenor's right to appeal applies only to the denial of his intervention and that he has no standing to question the main decision of the court if his intervention was denied. Petitioner merely joined Gallego's appeal instead of filing his own, which he had no legal personality to do. On the issue of whether RTC-Branch 138's Decision can be declared void in an action to quiet title: The Court held that the issues raised by the petitioner, such as fraud in the auction proceedings and denial of due process, cannot be resolved in an action for quieting of title. An action to quiet title is limited to determining if there is a cloud on a title due to an instrument, record, claim, encumbrance, or proceeding that has a prima facie appearance of validity. The petitioner's attempt to overturn the 19 December 1983 Decision of RTC-Branch 138, which cancelled his title, was beyond the scope of a quieting of title action. Such an action cannot be used to annul or modify the judgment of a co-equal court, as this would violate the doctrine of non-interference. The jurisdiction to annul a judgment of a regional trial court lies with the Court of Appeals. Moreover, petitioner's claim was anchored on a cancelled title, which could not cast a cloud on the Spouses Galang's current title. The finality of the RTC-Branch 138 Decision meant it was no longer subject to review. On the issue of whether petitioner is an indispensable party: The Court ruled that petitioner was not an indispensable party. An indispensable party is one whose interest is so vital that a final adjudication cannot be made without affecting it. The Court found that the decision quieting title in favor of the Spouses Galang had no appreciable effect on petitioner's cancelled title. The rules on quieting of title also provide that any declaration in such a suit shall not prejudice persons not parties to the action. Since petitioner's intervention was denied, he was not a party to the case and thus not bound by the judgment. The Court also clarified that the default order against Gallego did not ipso facto make petitioner the defendant. The Court noted that petitioner still had other remedies, such as recovering damages from parties who may have defrauded him.
Main Doctrine
An action to quiet title is not the proper remedy to annul or modify the judgment of a co-equal court. Furthermore, a cancelled certificate of title cannot cast a cloud on a current title, and a certificate of title under the Torrens system cannot be subjected to a collateral attack.